Environmental Considerations

Environmental Considerations - The starting point for
the development of all packaging systems ought to take into consideration
the six elements listed below. Responsibility for and demonstration of
a process for reporting and monitoring these elements are legally required
in many international markets.

Source
reduction requires demonstration that the minimum amount of packaging
materials have been used in the development of the package in order to
perform the main functions of protection, safety, storage, application
and marketing.

Limiting
heavy metals and other hazardous substances. Packaging must contain less
than 100 ppm of the sum of the concentration levels of lead, cadmium,
mercury and hexavalent.

Material
recovery and the availability of recycling infrastructure in the country
to which product is shipped.

Energy
recovery and the specification of minimum inferior calorific value.

Documentation burden
- Under the proposed draft, [European Committee for Standardization] product
manufacturers must assess their own packaging for compliance and maintain
in-house records that document compliance with the standards. Such assessment
documentation must be available for government review upon demand.

Each assessment that a manufacturer prepares must address
all packaging components for each packaging "system." A system
is defined as all primary, secondary and transport packaging associated
with a given product. For example, for source reduction, the company must
determine which functions of the package (protection, safety, storage,
application and marketing) are critical and how the packaging can be further
reduced without negative impact.

For recyclability, a manufacturer would be required
to determine which facilities are needed to recycle each packaging component
and if those recycling facilities exist in the country in which the package
is sold. For example, if Spain lacks the paper recycling facilities to
handle laminated paperboard, a packager cannot select recycling as its
recovery option.

The assessments must be retained for at
least two years (four in the U.K.) after a package is removed from the
market. Upon request, the responsible party (in most cases, the manufacturer)
will have to produce documentation showing that the packaging met the
requirements.